Pierce v. District of Columbia, 146 F. Supp. 3d 197

Plaintiff William Pierce, a profoundly deaf inmate, sued the District of Columbia under the ADA and Rehabilitation Act alleging failure to provide necessary communication accommodations while in custody.
At summary judgment both parties filed cross-motions; Pierce argued the District had an affirmative duty to assess and provide accommodations even absent an explicit request.
The District previously took the position at the summary judgment hearing that it had no duty to evaluate needs until an inmate requested a specific accommodation.
The Court held that prison officials have an affirmative duty to assess the accommodation needs of obviously disabled inmates taken into custody and to provide necessary accommodations without requiring a specific request.
The District moved for reconsideration under Federal Rule of Civil Procedure 54(b), arguing the Court exceeded the issues presented and misunderstood the District’s position; the Court denied the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prisons must affirmatively assess accommodation needs of obviously disabled inmates	Pierce: prison must engage and evaluate needs on intake; cannot wait for request	District: no duty to assess unless inmate requests a specific accommodation	Court: prisons have an affirmative duty to assess and provide necessary accommodations on intake
Whether Court exceeded issues presented at summary judgment	Pierce: claims and briefs raised statutory/regulatory duty to assess accommodations	District: Court went beyond issues argued	Court: analysis was within scope of pleadings and arguments; not beyond issues presented
Whether Court misunderstood District’s position at summary judgment	Pierce: District clearly argued no duty absent request	District: now contends Court misread prior statements and that informal assessments occurred	Court: District’s prior position was clear; claims of misunderstanding unfounded
Whether alternative factual holding (no request/no need) was erroneous	Pierce: record shows failure to request is not dispositive and need existed	District: reasonable jury could find Pierce did not request or need an interpreter	Court: alternative holding was proper; mere disagreement with outcome is insufficient for reconsideration

Prince George’s Hosp. Ctr. v. Advantage Healthplan Inc., 985 F. Supp. 2d 38 (D.D.C. 2013) (Rule 54(b) reconsideration standard explained)
Clayton v. District of Columbia, 931 F. Supp. 2d 192 (D.D.C. 2013) (circumstances warranting reconsideration described)
Singh v. George Washington Univ., 383 F. Supp. 2d 99 (D.D.C. 2005) (error-of-law assertions alone insufficient for Rule 54(b) relief)